Views on deregistration of e-TIN

Over the years, the number of e-TIN holders is increasing but the number of assessees filing tax return is significantly lower. During the fiscal year 2021, total e-TIN holders were 7.6m whereas only 2.6m filers submitted tax return, which represents only 31 per cent of the e-TIN holders, and in the last fiscal year, approximately 3.2m returns were submitted whereas total e-TIN holders were 8.6m, which represents only 37% of the e-TIN holders. Thanks to NBR for introducing the concept of Proof of Submission of Return (PSR) and making it mandatory for “certain services”.

A number of e-TIN holders who got registered to meet the statutory requirements are not filing tax returns due to their not having any source of income or leaving Bangladesh. Especially, a lot of foreign nationals have already left Bangladesh after their employment is over with their Bangladeshi employer. Besides, there are a lot of Bangladeshi nationals who left Bangladesh for blue or white colour job. As a matter of fact, some of them have left permanently or died. Though many of them have collected the final tax clearance, the rest of them or their successors do not file final tax return.

There are lots of liaison offices and branch offices which have not extended their registration after expiration of their approval from BIDA. These branch and liaison offices obtain final tax clearance from NBR in many cases. Some private limited companies opt for winding up. Moreover, there are a lot of dormant companies which do not file any statutory return.

Since there are no provision for de-registration, the government is proposing a provision for e-TIN deregistration as per the report from media.

Authority will be able to track down who are the active e-TIN holders and responsible for filing tax return. Individuals can relieve themselves from being unnecessarily chased by the authority for filing tax return. Incorrect e-TINs can be corrected through this process. This will reflect a proper ratio of filers.

E-TIN holders may opt for deregistration to avoid tax return submissions. Administrative work load will increase in order to minimize fraudulent applications. Authority may lose potential tax due to deregistration. Physical contact with authority may increase the chance of bureaucratic issues.

The writer is a faculty member, ICAB